Patrick J. McCurry

Patrick J. McCurry concentrates his practice on the corporate and tax aspects of complex business and investment transactions, with a particular focus on private equity funds, emerging businesses, partnerships and strategic joint ventures, limited liability companies and closely held corporations. He also has extensive experience in tax planning for high-net-worth individuals and families, and tax controversy matters. Read Patrick McCurry's full bio.

Latest Articles

Patrick McCurry and Todd Solomon wrote this bylined article on how family offices are using sophisticated techniques to compensate their employees in a tax-efficient manner. “We expect to see the continued use of equity to deliver tax-efficient compensation to family office employees while aligning the economic interests and incentives of the family and the family office’s key employees,” the authors wrote.
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Originally published in Tax Executive, February 1, 2018.…

On February 5, 2016, the IRS released Chief Counsel Advice 201606027 (the 2016 CCA) in which the IRS concluded, among other things, that guarantees by a partner of a partnership’s liabilities that could only be called by the partnership’s lenders in certain narrow circumstances (commonly referred to as “nonrecourse carve-outs” or “bad boy” guarantees), caused the guaranteed liabilities to be treated as “recourse liabilities” allocable solely to the guarantor partner under Treasury Regulation § 1.752-2…